We are required to keep records of your CCPA request for at least 24 months, including any assigned reference number, the request date and nature of the request, the manner in which the request was made, the date and nature of our response, and the basis for any full or partial denial.


  1. Verification Of The Person Making A Request.

We need to be reasonably sure that the person making the request about your PI is you, or a representative authorized to make a request on your behalf. We cannot comply with your request if we cannot verify your identity or your authority to make a request for another person. Accordingly, we will ask for information such as your full name, address, and date of birth to attempt to verify your identity and locate your records, if any.


To the extent possible, we will not ask you for new information to verify your identity, but instead will request information that we can cross-check against existing records. If we are unable to verify your request without new information, we will delete the new information as soon as practical after processing your CCPA request, except as may be required to comply with the CCPA’s record retention requirements.


We will never require you to create an account with us in order to verify your request, but if you already have an account we may use that information to assist with verification. We will only use information you provide to us during the verification process to try to verify your identity or your authority to make the request for another person.


Requests to access the specific pieces of information we may hold, and not just a list of the categories of information, require heightened verification procedures, and we will require you to submit a written declaration under penalty of perjury stating that you are the consumer whose PI is the subject of the request. In addition, certain pieces of information, such as a social security number, driver’s license number or other government-issued identification number or financial account numbers, will not be disclosed in response to a CCPA request.


If you wish to authorize someone else to act on your behalf in connection with your CCPA rights, we must receive proof that this person is authorized to do so. Proof can be provided by a consumer verifying his/her own identity directly with us and then providing written authority for a designated person to act on the consumer’s behalf, or through receipt of a power of attorney or other legal documentation of authority, or proof of registration with the California Secretary of State as a designated representative of another consumer. You may also make a verifiable consumer request on behalf of a minor child, which requires that you submit proof of your status as a parent or legal guardian.


  1. How and When Will We Respond?

Within 10 days of receipt of your request, we will provide an initial confirmation with an assigned reference number.


If you submit a Request to Delete, we are required to re-confirm your choice to delete the information after verifying your request, but prior to actual deletion.


The Company strives to provide a response within 45 days of receiving your request. If we need additional time, we will let you know.


We will send our response to your request by U.S. mail or email, at your option. Any information we provide will cover only the 12-month period preceding receipt of your request.


If we cannot respond to or comply with your Request to Know or Request to Delete, or we otherwise deny your request, we will explain our reasoning and decision in our response. We may, for example, deny a CCPA request if we cannot verify your identity or if the information we maintain for you is exempt from the CCPA, such as information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act.

We do not charge a fee to process your request unless it is excessive, repetitive, or manifestly unfounded, and we have informed you in writing of the reasoning behind a charge and its estimated cost. We will provide a cost estimate before completing your request if we determine that a charge is warranted.